EU CBAM from 01 January 2026:
What should exporting companies prepare to continue accessing the European market?
Global climate policy trends and the risk of “carbon leakage”
Climate change is a global challenge that requires global solutions. In recent years, the European Union (EU) has significantly strengthened its climate policies in order to achieve carbon neutrality and reduce greenhouse gas emissions.
However, as climate regulations within the EU become increasingly stringent while many other countries continue to apply less rigorous policies, a major risk may arise known as “carbon leakage.”
This phenomenon occurs when:
- EU companies relocate carbon-intensive production activities to countries with less stringent climate regulations; or
- Products manufactured within the EU are replaced by imports with higher carbon emission intensity.
To address this issue, the European Union has established the Carbon Border Adjustment Mechanism (CBAM).
CBAM – A landmark climate policy instrument of the EU
CBAM is designed to:
- Apply a carbon price to imported goods entering the EU
- Ensure that the carbon price of imports is equivalent to that of products manufactured within the EU
- Encourage cleaner industrial production worldwide
CBAM is also designed to be compatible with World Trade Organization (WTO) rules, ensuring that the mechanism does not create unfair trade barriers.
This mechanism will operate alongside the EU Emissions Trading System (EU ETS), under which free allowances allocated to EU industries will gradually be phased out between 2026 and 2034.
EU CBAM implementation roadmap
Transitional period (01 October 2023 – 31 December 2025)
CBAM officially entered into force on 01 October 2023, aiming to create a learning and testing phase for both businesses and regulatory authorities.
During this period:
- EU importers are only required to report the greenhouse gas (GHG) emissions embedded in imported goods.
- No carbon payment obligations apply.
The sectors currently covered under CBAM include:
- Cement
- Iron and steel
- Aluminum
- Fertilizers
- Electricity
- Hydrogen
These sectors account for more than 50% of emissions in industries covered by the EU ETS.
CBAM officially applies from 01 January 2026
From 01 January 2026, CBAM will enter its full implementation phase.
At that time:
- EU importers must annually declare the carbon emissions embedded in imported goods.
- They must also purchase and surrender CBAM Certificates corresponding to the amount of CO₂ emissions.
The price of CBAM Certificates will be determined based on the weekly average auction price of the EU Emissions Trading System (EU ETS) (€/ton of CO₂).
This means that:
Products with higher carbon emission intensity will face higher carbon costs when imported into the EU.
Impact on companies exporting to the EU
In practice, within international supply chains, EU importers and multinational corporations will require suppliers from countries such as Vietnam to:
- Provide CO₂ emission data for their products
- Establish emissions inventory systems
- Ensure transparency and traceability of carbon data
If companies are unable to provide reliable emissions data, the EU may apply default emission values, which are typically significantly higher than actual emissions.
This could result in:
- Increased import costs
- Reduced competitiveness
- Risk of losing orders from EU customers
What should companies do to comply with CBAM?
To comply with CBAM requirements, exporting companies need to establish a comprehensive carbon management system, including:
1. Identify products within the CBAM scope
- Analyze HS Codes
- Identify relevant sectors
- Identify raw materials and precursors
2. Establish an emissions data management system
- Collect energy consumption data
- Manage production data
- Develop an MRV system (Monitoring – Reporting – Verification)
3. Conduct carbon emissions accounting for products
- Calculate direct emissions (Scope 1)
- Calculate indirect emissions from electricity (Scope 2)
- Determine the carbon intensity of products
4. Develop CBAM technical documentation
- Description of production processes
- Energy consumption data
- Emissions calculation methodologies
- Supporting documentation and data traceability
5. Verify emissions data
- Internal assessment
- Independent verification
6. Provide CBAM data to EU customers
- Embedded emissions
- Exported product quantities
- Carbon price already paid in the country of production (if applicable)
7. Reduce emissions to maintain competitiveness
- Optimize energy consumption
- Utilize renewable energy sources
- Improve production technologies
VINTECOM International supports companies in implementing CBAM
With extensive experience in implementing international standards for FDI supply chains and export-oriented enterprises, VINTECOM International provides CBAM training, consulting, and system assessment services, including:
CBAM Training for Companies
- EU CBAM Regulation
- Embedded emissions calculation methodologies
- MRV system implementation
Consulting on Carbon Inventory Systems
- Establishment of emissions data management systems
- CO₂ calculation methodologies aligned with EU requirements
- Development of CBAM technical documentation
Emissions Data Assessment and Verification Support
- Carbon inventory system assessment
- On-site evaluation
- CBAM documentation verification for EU customers
Supporting companies in EU supply chains
Typical industries include:
- Steel
- Aluminum
- Electronics
- Automotive supply chains
CBAM is becoming an important climate–trade mechanism of the European Union and will have a direct impact on global exporting companies starting from 2026.
Companies that wish to maintain access to the EU market need to:
- Establish emissions inventory systems
- Ensure transparency of carbon data
- Comply with CBAM reporting requirements
Early preparation will help companies reduce carbon costs and maintain competitiveness within global supply chains.
CBAM Consulting & Compliance Support
Organizations and enterprises wishing to register for CBAM consulting and compliance support – Carbon Border Adjustment Mechanism (CBAM) for exports to the EU market, please contact:
📶📶📶 Contact us to register for EU CBAM 2026 Training, Consulting and Certification
Customers, organizations and enterprises require Training course, Consulting or Certification services of EU CBAM 2026, please click on "Registration - Quotation" or on the right toolbar below the PC screen to receive a quotation for training, consulting and certification services.
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📶📶📶 Further information, Please contact us as below:
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